Special Report No. 83-11: Raw Waste Load Control Measures in Use at Selected U.S. Pulp, Paper, and Board Mills

In 1980 the U.S. Environmental Protection Agency proposed Best Conventional Pollutant Control Technology (BCT) effluent limitations guidelines for the pulp, paper and paperboard industry. In reviewing the then proposed BCT guidelines, the industry identified several areas where the guidelines development process was flawed. Among these were (a) an inappropriate test had been used for judging the reasonableness of the costs of compliance with BCT, and (b) EPA had considered only the costs for upgrading external treatment operations. The industry recognized that the mills used by EPA to derive BCT guidelines had spent significant amounts of money installing and operating a variety of in-process load controls to reduce raw waste loads.